ML20215L146
| ML20215L146 | |
| Person / Time | |
|---|---|
| Issue date: | 09/12/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| REF-GTECI-124, REF-GTECI-NI, TASK-124, TASK-OR ACRS-2458, NUDOCS 8610280496 | |
| Download: ML20215L146 (28) | |
Text
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Y' '
h$hclY$$
- W h)h[1fi! U, i Twx ^%um DATE ISSUED
- 9/12/86 h 6 k bi-fl1& ADVISORY COMMITTEE ON REACTOR SAFEGUARDS DECAY HEAT REMOVAL SYSTEMS SUBCOMMITTEE MEETING MINUTES SEPTEMBER 9, 1986 WASHINGTON, DC PURPOSE: The purpose of this meeting is to review NRR's Action Plan to address concerns with the reliability of certain plants' AFW systems via Generic Issue 124: "AFW System Reliability."
ATTENDEES: Principal meeting attendees included:
NRC ARKANSAS POWER ACRS D. Ward, Chairman W. Minners AND LIGHT J. Ebersole, Member S. Diab T. Enos C. Michelson, Member F. Manning I. Catton, Consultant J. Callan P. Davis, Consultant R. Hernan P. Boehnert, Staff R. Dennig M. Williams A complete list of meeting attendees is attached to the Office Copy of these Minutes.
MEETING HIGHLIGHTS, AGREEMENTS AND REQUESTS Mr. Ward convened the meeting at 1:00 p.m. He reminded the Subcom-1.
mittee of the history of this issue and noted ACRS concern with lack of a definitive resolution schedule via a December 1985 letter to the EDO.
Noting the Subcommittee meeting in March 1986, Mr. Ward said NRR has revised their resolution approach. The ACRS may want to review and comment on the present resolution approach given the results of today's meeting.
DZ;20::A:ZD Oi?IGI!iAL h 6 860912 Certified By 6 46
- 2458 PDR
i DHRS Meeting Minutes September 9, 1986
- 2. S. Diab (NRR) introduced the discussion of Generic Issue 124 -
" Auxiliary Feedwater System Reliability." In response to Mr. Ward as to why issue is now focused on seven PWR plants (see below), Mr.
Diab indicated that as a result of reliability analyses required after the THI-2 accident, seven plants showed lower reliability than desired (10 10-5/ demand). Mr. Diab said the seven plants with only two AFW pumps (one/ train) showed significantly lower reliability than plants with three pumps and/or three trains. In response to Mr. Ward, Mr. Diab said most plants need to rely on the AFW system (AFWS) for startup and shutdown. Some plants have "startup pumps" to avoid use of AFW. Mr. Ward said NRR should take account of the challenge frequency vis-a-v h a plant's respective arrangement for startup and cooldown ('<FW pumps versus startup pumps versus use of main feed pumps, etc.). Mr. Ebersole suggested NRR evaluate the various pump drive options in use vis-a-vis the AFW challenge rate. Mr. Minners (NRR) said NRR is basically taking a plant-specific approach to resolution of the issue.
NRR noted this discussion is a status report and that they are proposing a modification of the resolution plan discussed at the March 26, 1986 Subcommittee meeting.
As a result of NRR Management comment on the earlier resolution approach and a concern with the length of time involved to conclude resolution, NRR has modified their resolution approach. The new approach involves a short-term concentrated review effort followed by an "AFW Review Findings Report" for each of the seven plants.
The review effort will benefit from the I&E SSFI (Safety System Functional Inspection) Program, the Prairie Island AFWS reliability analysis and other Industry and Staff efforts. NRR characterized it as a two-tier approach for: (1) the seven plants of concern, In response to Mr. Ward, NRR said and (2) the rest of the PWRs.
Item (2) will be coordinated with the USI A-45 resolution effort (i.e., no specific action will be taken vis-a-vis this Issue).
DHRS Meeting Minutes September 9, 1986
- 3. R. Dennig (AE0D) introduced the AE0D presentation. AE0D has been supporting the GI 124 resolution effort including review of the NPRDS data as well as LER data.
F. Manning (AE0D) detailed the AE0D Analysis of AFW system opera-tional data to support the GI 124 resolution effort. The scope of the study was to use LER and NPRDS data from 1981-85 (inclusive) for the seven piants of concern (ANO-1 Units 1 & 2, Crystal River 3, Ft. Calhoun, Prairie Island Units 1 & 2 and Rancho Seco).
Mr. Michelson asked AE00 if they have an estimate of how many AFW-related failures are escaping reporting via NPRDS. Mr. Dennig indicated that they didn't know. In response to Mr. Ward, AE0D said the NPRDS has improved to the point where they are capturing almost all LER events. They are looking for a way to increase confidence that an even greater percentage of significant events are captured.
Noting that the operational data is not directly usable and must be massaged, AE0D performed a two-phase study: (1) use of LER data, above, for qualitative insights, and (2) use of LER and NPRDS data to develop quantitative insights of the AFW system reliability for the plants of concern.
Results of the Phase I work were summarized as: (1) each plant has its own particular problems; (2) problems can go uncorrected for long periods; and, (3) AFWS reliability can have large variations with time. In response to Mr. Michelson, Mr. Williams (NRR) noted that NPRDS is examined for trends or problems in plant components but on a selective basis. Mr. Michelson said NPRDS is not general-ly used in a regulatory sense as a screening tool.
September 9, 1986 DHRS Meeting Minutes Phase 2 efforts included use of NPRDS records in an analysis.
Generic failure rates were used to estimate expected failure rates and the .xpected e failure rates were compared with reported failures. AE0D performed a sample calculation for turbine driven pump failures (Figure 1). The results (Figure 2) indicate that the ,
plants of concern had failure rates significantly higher than projected by AE00. Also there is a large variation in the failure rates from plant to plant.
In There was extensive discussion of the failure rate data above.
response to Mr. Ebersole, AE00 indicated that no system failures have been seen because of the redundancy in the AFWS, In response to Mr. Ward on the variation in failure rates seen, NRR indicated that the plants with lower failure rates (e.g., Prairie Island) should indicate a more reliable system. Mr. J. Callan (I&E), NRC, noted that he was former RI at ANO. He said that the failure rates shown are heavily skewed towards the early operation phase when For example, the high problems first manifested themselves.
failure rate shown for the AFW flow control valves is moot as these valves have been replaced.
AE0D concluded the following:
Higher than normal failure rates were seen for some AFWS components.
AFWS testing emphasizes start on demand - endurance is also important (and probably should be considered).
Potentially significant AFWS problems (e.g., bearing failure) are being increasingly reported in the less visible NPRDS (rather than the LER system).
DHRS Meeting Minutes September 9, 1986 Mr. Michelson said he sees little value to the above failure rate information since the data base is suspect (significantly incomplete). In response to Mr. Minners, Mr. Michelson said the NPRDS reporting should be made mandatory in order to assure a sound data base.
- 4. The results of the SSFI for the AN0 Unit 1 AFW system was presented by J. Callan (I&E). Mr. Callan began by reviewing the extensive number of modifications made to the Unit 1 AFWS over the past 4-5 years starting after the TMI accident (Figures 3-8). In response to Mr. Ward, Mr. Callan indicated a portion of the component failures seen above was the result of the extensive design and hardware modifications noted. These modifications were phased in over the years as part of a " master plan." Figures 9 and 10 contrast the original and current AFWS.
The result of the SSFI was favorable. The operators reported high confidence in the AFW system. No significant design problems were identified. A problem was identified with the check valves in the steam admission system (Figure 11) which, given a steam line break and a single failure of a M0V (Figure 11 - arrow), could result in loss of both the steam and motor driven pumps (i.e., the entire AFWS). The licensee corrected the problem by installation of check valves (Figure 12). This was cited as an example of how flaws can be introduced via design changes.
Mr. Davis said the above DBA has a rather low probability and suggested that I&E should take account of the significance of the given risk contributor (major / minor) for future inspection ieviews of this type. Messrs. Ebersole and Michelson asked if dynamic tests of the check valves to withstand full flow was performed.
Mr. Callan replied in the negative.
DHRS Meeting Minutes September 9, 1986
He noted that AP&L spent $20M on upgrade of the ANO Unit 1 AFWS over 4-5 years. He also detailed the competing rationale for deciding to install the steam line check valves noted above.
Regarding the check valve dynamic performance question noted above, AP&L is changing out these valves, partially to resolve this concern. Other points noted included:
AP&Ls analysis of AFWS reliability shows that the reliability is~ 1/ better than the industry average.
Recent data (1985-on) indicates that the AFWS failure rate is very low compared to the industry average (one failure of the ANO-Unit 2 AFWS that would prevent delivery of water to the steam generators).
A canvass of plant operator logs indicates that the AFW pumps are seeing a total of at least 100 demands to start each year.
This results in comoonent failure rates in the 10-3/ demand range.
In response to J. Ebersole, Mr. Enos said the ECCS vent line on the pressurizer is there as a last-ditch pressure relieving / decay heat removal capability (Figure 13).
In response to Mr. Michelson, Mr. Enos said the SSFI Program has merit, but on the downside it is extremely resource inten-sive for the Licensee (
- 2-3 MY spent on their SSFI).
Mr. Davis indicated that he is troubled by the lack of consid-eration of a risk-based versus a deterministic approach to the SSFIs. Mr. Enos shared his concern and indicated that he believes NRC and the Industry is slowly moving to a risk based philosophy in regulation. Mr. Ward urged I&E to give consid-eration to risk-based analysis as well.
DHRS Meeting Minutes September 9, 1986
- 6. The NRR resolution approach for GI 124 was detailed by S. Diab. In response to Mr. Michelson, Mr. Diab said no additional SSFI's are planned for any of the remaining plants of concern.
The key aspects of the review for each plant of concern is outlined in Figures 14-16. NRR has formed a Review Team to resolve this Generic Issue. This will be a five person Team, four from NRR and one from I&E. Figures 17-18 outline the Team's review scope. The Team's firdings could range from " acceptable reliability" to
" unacceptable without major modifications." Any recommended backfits will be subjected to the provisions of the Backfit Rule.
Mr. Ward noted that NRR has backed away from quantitative goals to words like " assure the AFWS is adequate and sufficiently reliable."
He asked what the NRR benchmark will be here (basis for judgment)?
Mr. Diab said their benchmark wiil be subjective and will be compared to a " good" plant on the list (i.e., Prairie Island). The plants will be compared to each other. The gist is that if each plant can demonstrate a 10-5 "unreliability" (as benchmarked to Prairie Island), via inspection of key aspects of the AFWS, they will be acceptable. The current schedule for the Review Team plant visits is given in Figure 19. Visits are scheduled for Prairie Island, ANO-2 and Ft. Calhoun. Given the ongoing B&W-related and plant-specific Programs, visits to AN0-1, Rancho Seco and Crystal River may not be needed.
Reliability estimates of the Prairie Island AFWS performed by the Applicantwereshown(Figure 20). The best estimate (BE) reliabilities, given post-TMI modifications ( m 10 10-5), are under review by the Staff. Mr. Davis felt the 10-5 estimates appear to be too low for a typical two-train AFWS, given CMF considerations. He indicated that if one can believe the Prairie Island reliability values, there really isn't a problem with these
September 9, 1986 DHRS Meeting Minutes plants. In response toMr. Hernan, Mr. Diab indicated that some (or all) of the seven plants of concern may now meet the SRP reliabili-Mr.
ty criterion, given the numerous post-TMI modifications made.
Minners said the Staff is not fully cognizant of the state of the AFWS given the post TMI modifications. Mr. Diab said the results of the reviews will be based primarily on engineering judgment (the "old fashioned" approach).
- 7. Mr. Ward said one hour had been allotted at the September ACRS meeting for discussion of this issue as necessary. Mr. Ebersole indicated that the ACRS should hear this issue in light of the "old fashioned" approach being taken. Mr. Ward said the basic concern with these plants is their 2-train AFWS. He said the choice is either to put in another train or show via operations, maintenance',
etc., that its acceptable. Mr. Diab said its alot harder to 10 0 unreliability given a BE approach (human demonstrate 10 error,CMF,etc.). These factors are not considered in the SRP analysis.
Mr. Ward said he personally has concerns with the resolution approach (i.e., there does not appear to be a sound criterion by which one can demonstrate adequate reliability). He requested a NRR presentation at the September ACRS outlining the above approach.
- 8. The meeting was adjourned at 5:20 p.m.
NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 1717 H Street, N.W, Washington, DC, or can be purchased from ACE-Federal Reporters, 444 North Capitol Street, Washington, DC20001,(202) 347-3700.
SAMPLE CALCULATION OF EXPECTED TD PUMP FAILURES
- USE GENERIC UNAVAILABILITY, 0 = 10-2/ DEMAND .
ASSUME TD PUMP COMMANDED ON = APPR0X. 15 TIMES / YEAR PERIOD EVALUATED = APPR0X 5 YEARS o
, , (15)(1E-2)(5) = APPR0XIMATELY 0.8 ESTIMATED EXPECTED FAILURES PER PLANT
~
p N
/ .
/ .
MAJOR CATEGORIES OF REPORTED AFWS FAILURES AFW PUMP FAILURES ,
FAIL To START Fall To RUN AFW FLOW AFW FLOW PLANT NAME TD MD TD AND MD INSTRUMENTATION CONTROL VALVES ANO-2 9 0 1 0 37 CR-3 8 2 5 7 3 ANO-1 6 6 9 0 8 RANCHO SECO 5 1 3 7 2 FT, CALHOUN 3 1 1 0 14 PRAIRIE I. 1 3 0 0 0 0 PRAIRIE I. 2 3 0 0 0 0 EXPECTED 0,8 -
- 0. fi 0,09 0.6
. 'i.
/
ANO-1 POST TMI RESTART MODIFICATIONS (1979) o MOTOR DRIVEN PUMP ICS AUTC START o CONTROL GRADE FLOW INDICATION o
CONTROL GRADE ANTICIPATORY REACTOR TRIP LOSS OF BOTH MFW PUMPS TURBINE TRIP o
EFW AUTO START ANNUNCIATION IN CONTROL ROOM .
l
/
- j 1980 EFW SYSTEM 'MODIFICA TIONS I
o NNI AUTO INITIATION LOSS OF ALL RCPs LOSS OF MFW PUMPS LOW OTSG LEVEL o MOTOR DRIVEN PUMP CONNECTED TO SAFETY GRADE POWER o SAFETY GRADE FLOW INDICATION o SW SUCTION - REDUNDANT SOURCE o EFW LOW SUCTION PRESSURE ALARM o SAFETY GRADE ANTICIPATORY REACTOR TRIP LOSS OF MAIN FEEDWATER TURBINE TRIP ;
o UPGRADED NNI POWER SUPPLIES (CR-3) o MOTOR G TURBINE DRIVEN PUMP BEARING COOLING SYSTEM ADDED p,_ , - . .,,--.--,--T-v-r--= YwwP'w"'""'* *'?*'" * -
- l. '
1982 EFW SYSTEM MODIFICATIONS o EFIC CABINETS INSTALLED AND POWERED o NEW C09 INSTALLED o OTSG LEVEL MEASUREMENT SYSTEM OTSG LEVEL TAPS NEW LEVEL TRANSMITTERS EFIC COMPENSATION INDICATION ON C09 INDICATION ON SPDS o OTSG PRESSURE MEASUREMENT SYSTEM MSL TAPS PRESSURE TRANSMITTERS EFIC COMPENSATION INDICATION ON C09 INPUT TO STEAM LINE ISOL. SYSTEM INDICATION ON SPDS o PROTECTION SYSTEM INPUTS TO EFIC RPS, LOSS OF RCPs, LOSS OF MFWPs ESAS LOSS RCS PZR OR HIGH RB PZR A -
l l
1982 EFW SYSTEM MODIFICATIONS (Continued) o NEW EFW TURBINE DRIVER INSTALLED ELECTRONIC SPEED CONTROL W/ RAMP EXISTING STEAM ADMISSION VALVES TO STEP OPEN EFW STEAM PIPING MODIFIED NEW DC STEAM ADMISSION VAL VES WELDED IN - LOCKED GPEN o EFW RELATED ANNUNCIATION CONSOLIDATED ON K12 J
/m 7/
1 r*
1983 - 84 EFN DESIGN ACTIVITIES o DISCHARGE PIPING DESIGN o
ELECTRICAL COMPONENT INTERFACE DESIGN o ENVIRONMENTAL QUALIFICATION o INCLUSION OF SETPOINT ANAL YSIS l
l
.I v'
1984 EFW SYSTEM MODIFICATIONS o
EFW DISCHARGE PIPING G VAL VES INSTALLE o
EFIC CONNECTED TO CONTROLLED COMPONEN o .
EFW AND EFIC CONTROLS INSTALLED ON C09 o
EFW AND EFIC ANNUNCIATION INSTALLED o
SAFETY GRADE OC MCCs INSTALLED o
EFW TURBINE DRIVER STEAM ADMISSION S CONNECTED l'
,1 I l1
.B A G G T
n' '
S O
T S
O M' -
h, N N M [g ,
j M 4 i>k '
" 4@>< N O
n l I
T' A
R MU l
TG E OF
- I EN N RO APC m I M
N N M
4 m
{ -
O m u
) ,
m E 'i
)
AIN 8R 7O 7BR T PU m T
(
PO M (
(
M' m E :
CR a I
VE i d
n a
m
/.
\. o
+ r 1 a r L 3a a
y s .
a m
n <
a m
% T R M
E u S E M a S U C N f E L D F m N m O l i a 7, C e
m
-~%
! "O" CST -
\/ 11 a gl,
, , CV3850 l- -J ,
l l ! YARWAY CHA CHD CV 2003 RECIRC CV 2646 CV 2670 l
J 3
LM g t--
I d l l
s VALVE p j A STEAM g ) '
ll 'k' C a' -* GENER ATOR l EFW l
h - CHC l- l P78 '1: h 645 CV 2627 HEADER MOTOR FI S NJ CV2800gl p I l
DRIVEN CH. A ,,
J
TO CST d- zTO FLUME : D 4--I . - O g , FC " .CV 2870 TO CONDENSER J L g
l mT2AC M YARWAY CV2869_ _ CHC l LE hFI S hN647
.g m R .T. I B STEAM
, ( lN i=
]
CV 2006 P7A
\ ss 1
CHA CV 648 CHD CV2626
g
' CH. B DC AC CV 3851 l A ANO-1 PRESENT r SW LOOP 2 . CONFIGURATION 5
h '
F -
o .
ICS(LOW VACUUM) TRN A TRN8 CONT ICS(LOW VACUUM) x TRN A MSLI CONT TRN O MSLI CV 2676 CV 2668 CV 2618 CV2619 FC FC TRN A MSLI 8 SAFETY 4 D d->- ATMOS Md r, OR TRN 8 MSLI VALVES 8 SAFETY TRN A MSLI CV 2691 TRN A EFW VALVES TRN 8 EFW OR TRN O MSLI CV 2692 sTT"AM A <
CV 266G A r STEAM -
1 8
GEN STEAM TRN 8 EFW-- n, f SV f'e- r---- TRN A EFW GEN CV 2613: 2 613
' CV 2663 DC hi 2!63 h DC U U TRIP THROTTLE VALVE GOVERNOR VALVE lf K3
)
ANO-l MAIN STEAM SYSTEM 1985 CONFIGURATION
[
w
ANO-1 STEAM ADMISSION TO .
TURBINE FOR EFW PUNP P-7A
( JANUARY,1986 )
O O A >d 'i '/ >d B
/ /
O I
l
s' NO-ECCS VENTS TOP RELIEFS TO QUENCH TANK c n
6" 6"
? ?
hl
[d!
=
, 4.. 4..
3" EL 6 4- .
6" PRESSURIZER Iex. aJ
GI 124 THE SEVEN PLANTS ANO-1
- SSFI DISCUSSED BY OIE
- WILL BE REVIEWED BY REVIEW GROUP
- B8W OG FOR DESIGN REASSESSEMENT l
RANCHO SECO RESTART EFFORT
- RESTART EFFORT
- EXTENSIVE MULTIDECIPLINE STAFF REVIEW 0F AFWS (AMONG OTHER SYSTEMS)
- DESIGN MODS
- PROCEDURES & TRAINING
- SUPPORT SYSTEMS
- INDICATION & CONTROL
- B8W OG FOR DESIGN REASSESSEMENT fll$-
CRYSTAL RIVER hjsit G 6
'JEASSESN DESIGN REASSESSEMENT
- LICENSEE'S RELIABILITY ANALYSIS I -
L e
l l
l l
1
_ _ _ _ _ . _ _ _ _ - _ _ . _ . _ _ _ - - _ . _ - _ - - - - _ - . _ _ . _ _ _ _ . . _ _ _ . _ _ _ _ J ._.
PRAIRIE ISLAND - 1 8 2
- AFWS RA CURRENTLY UNDER STAFF REVIEW
- CONSIDERS ELEMENTS REQUESTED BY STAFF
- EENCHMARKED AGAINST NUREG-0611
- ESTIMATED HIGH AFWS RELIABILITIES
! - ESTIMATED RELIABILITIES NOT YET VERIFIED
- THE HIGHEST CAPACITY FACTOR FOR 1983 THROUGH 1985
- REPORTED AS ONE OF THE BEST. MANAGED PLANTS IN THE COUNTRY ANO-2
- AFW REVIEW GROUP
- DEDICATED BLEED & FEED ARRANGEMENT
- LICENSEE'S RELIABILITY ANALYSIS FT CAHOUN
- AFW REVIEW GROUP
REVIEW PROGRAM REVIEW TEAM
- A FIVE PERSON TEAM PLUS A TEAM LEADER S # # # /
- PRELIMINARY DISCUSSIONS WITH PROSPECTIVE TEAM MEMBERS
- TEAM SHOULD START OPERATION WITHIN A WEEK REVIEW SCOPE
~
- AREAS TO BE COVERED ARE SHOWN ON TABLE 1
- AFW AND SUPPORT SYSTEMS
- AUDIT SELECTED PREVENTIVE AND CORRECTIVE MAINTENANCE ACTIVITIES DURING LAST 12 MOS,
- AUDIT SELECTED SURVEILLANCE TESTING PROCEDURES AND POST MAINTENANCE TESTING I
i fb. __
/ .
O TABLE 1, AREAS COVERED BY STAFF REVIEW 1, P8 ids AFWS, ADVs, PORVs (FEED & BLEED)
SUPPORT SYSTEMS (E.G., POWER SUPPLIES, COMPRESSED AIR OR NITROGEN
- 2. FSAR SYSTEMS, LUBRICATION, COOLING)
- 3. SYSTEM DESCRIPTION
- 4. TECHNICAL SPECIFICATION 5,
f 18C LOGIC DI GRAMS
- 6. SERs SINCE 1980
~
- 7. MAINTENANCE (PREVENTIVE PROGRAMS, CORRECTIVE ACTIVITIES)
LAST 12 MOS
- 8. SURVEILLANCE TESTING (FEW PROCEDURES AND RESULTS, POST MAINTENANCE TESTING LERs, NPRDS, SOEs, R0s, A0s, DURING THE LAST 12 MOS
- 9. EMERGENCY OPERATING PROCEDURES (LOSS OF HEAT SINK)
- 10. F8 BLEED PROCEDURES (SEE 9 AB0VE), TRAINING (YES/N0) l
i SCHEDULE REVIEW TEAM VISIT REPORT 1
P. ISLAND 182 SEP, 29, 1986 Nov. 3, 1986 ANO-2 NOV. 17, 1986 DEC, 22, 1986 FT CALHOUN JAN. 5, 1987 FEB. 9, 1987
, ANO-1 NOTE (1) NOTE (2)
- R. SEC0 . NOTE (1) NOTE (2)
_ C. RIVER NOTE (1) NOTE (2)
NOTE (1) THE NEED FOR AND SCHEDULE OF VISITS TO THESE PLANTS WILL BE DETERMINED IN LIGHT OF THE ONGOING STAFF WORK ON THESE PLANTS, NOTE (2) REVIEW TEAM REPORTS FOR THESE PLANTS WILL BE COORDINATED W ONGOING STAFF EFFORTS.
i A
Pu R
PRAIRIE ISLAND AFWS RELIABILITY STAFF LICENSEE BENCH MARK
- BEST EESTIMATE' NUREG 0611 PRE 1hi Fusi IMI Fust IMi g g a m'f '.,'
1,OE-3 1;fu s
i
' /n v.l M W LOOP 1.0E-3 3.4E-3 5.4E-5 8,7E-5 .es/c/*
'AFWS RELIABILITIES ESTIMATED BY LICENSEE AND HAVE NOT YET BEEN VERIFIED,
.